Meritor Savings Bank v. Vinson
Identification U.S. Supreme Court decision
Date June 19, 1986
The Supreme Court’s unanimous ruling prohibited an em-
ployer from subjecting an employee to a sexually hostile work
environment. It confirmed the legality of the EEOC’s sexual
harassment guidelines and prompted a significant change
in U.S. workplace policies and corporate culture.
At the timeMeritor Savings Bank v. Vinsonwas
brought to court, the Equal Employment Opportu-
nity Commission (EEOC) defined sexual harass-
ment as unwelcome sexual advances, requests for
sexual favors, and other verbal or physical conduct
of a sexual nature that met any of three specific crite-
ria. First, harassment would result if submission to
such conduct was made a term or condition of an in-
dividual’s employment. This was called “quid pro
quo” sexual harassment. Second, if submission to or
rejection of such conduct was used as a basis for em-
ployment decisions affecting the employee in ques-
tion, that would also constitute quid pro quo harass-
ment. Third, sexual harassment would also result
from conduct that had the effect of unreasonably in-
terfering with an individual’s work performance or
creating a hostile, intimidating, or offensive working
environment. This was known as “hostile work envi-
ronment” sexual harassment.
The case resulted from Mechelle Vinson’s lawsuit
against her employer, Meritor Savings Bank. Vinson
claimed that on numerous occasions she had sub-
mitted to the sexual advances of her supervisor in or-
der to keep her job. Evidence at trial revealed that
Vinson was hired as a teller-trainee and subsequently
promoted to teller, head teller, and assistant branch
manager. She was discharged for excessive use of
sick leave. She said that she engaged in noncon-
sensual sex with her supervisor forty to fifty times in
a four-year period in order to keep her job and that
he fondled her in front of other employees, followed
her into the restroom, exposed himself to her, and
forcibly raped her on several occasions. The supervi-
sor and the bank denied these allegations.
The EEOC had defined sexual harassment in or-
der to enforce Title VII of the Civil Rights Act of
- The Supreme Court was thus faced with the
task of determining whether the EEOC guidelines
were legitimately authorized by that law. The defen-
dants argued that the law applied only to tangible or
economic discrimination, not something as intangi-
ble as the workplace environment.
The Court determined that the creation of a hos-
tile work environment through sexual harassment
was indeed outlawed by Title VII, whose prohibi-
tions included unwelcome verbal or physical sex-
ual behavior that is so extreme or widespread as to
subject the employee to psychological strain and
create a hostile working environment, altering the
conditions of employment. The Court rejected the
idea that there could be no sexual harassment just
because the sexual relations between the parties
were voluntary. The core of a sexual harassment
claim, under the Court’s decision, was that the sex-
ual advances were unwelcome. So long as harassing
behavior offended the sensibilities of an individual
employee, it could constitute sexual harassment.
Therefore, each case was to be analyzed based on
its own specific facts.
Impact After the decision inMeritor Savings Bank v.
Vinson, sexual harassment law evolved, and employ-
ees grew increasingly aware of their right to be free
from sexual harassment in the workplace. Em-
ployers instituted policies against discrimination and
sexual harassment and conducted training sessions
for human resource officers and managers. The
Court’s ruling had far-reaching implications in the
workplace and also influenced such later high-pro-
file controversies as the Anita Hill-Clarence Thomas
hearings, the Tailhook scandal, and the Bill Clinton
impeachment.
Further Reading
Cochran, Augustus B.Sexual Harassment and the Law:
The Mechelle Vinson Case.Lawrence: University of
Kansas Press, 2004.
Goldstein, Leslie Friedman.The Constitutional Rights
of Women. 2d ed. Madison: University of Wiscon-
sin Press, 1988.
Hoff, Joan.Law, Gender, and Injustice: A Legal Histor y
of U.S. Women. New York: New York University
Press, 1991.
Mazey, Susan Gluck.Elusive Equality: Women’s Rights,
Public Policy, and the Law. Boulder: University of
Colorado Press, 2003.
Marcia J. WeissSee also Feminism; Sexual harassment; Supreme
Court decisions; Women in the workforce; Women’s
rights.The Eighties in America Meritor Savings Bank v. Vinson 635